Modern courts have consistently held that the rights of free speech and press provided for in the first amendment are fundamental rights protected by the due process clause of the fourteenth amendment from abridgment by the states. Student expression has been the target of much recent litigation and has prompted increased Supreme Court concern over constitutional aspects of public school administration. The central controversy has developed into a question of how much freedom should be given to a generation that delights in exploring the "limits of institutional response." One of the most piercing probes has been the campus newspaper which has recently been afforded a limited degree of first amendment protection.